EU DPP Glossary — Digital Product Passport Terms Explained
Core DPP and EU compliance terms defined in plain English, with regulation references. New terms added as the regulatory landscape evolves.
A
Annex XIII
Annex XIII of EU Battery Regulation 2023/1542 specifies the information to be included in a battery passport. It is organised as four numbered points, and each point is an access tier rather than a subject area: point 1 is publicly accessible information relating to the battery model, point 2 is battery model information for persons with a legitimate interest and the Commission, point 3 is test reports for notified bodies and market surveillance authorities, and point 4 is data relating to an individual battery for persons with a legitimate interest. Point 1(a) incorporates Part A of Annex VI by reference.
EU Battery Regulation 2023/1542, Annex XIII
Read the full regulatory guide →Authorised Representative
A natural or legal person established in the EU who has been mandated by a manufacturer established outside the EU to act on their behalf in relation to specified obligations under EU product legislation. The authorised representative can be the responsible party for DPP obligations.
ESPR 2024/1781, Article 4
Read the full regulatory guide →B
Battery Passport
A machine-readable data record that accompanies every EV, LMT, and industrial battery above 2 kWh placed on the EU market from February 18, 2027. The battery passport contains data specified in Annex XIII of Regulation 2023/1542, accessible via a QR code and unique identifier.
EU Battery Regulation 2023/1542, Article 77
Read the full regulatory guide →C
Carbon Footprint Declaration
A documented statement of the carbon footprint of a product, typically expressed per functional unit (e.g., kg CO2e per kWh for batteries). Required under Annex XIII for battery passports and expected for other ESPR product categories.
EU Battery Regulation 2023/1542, Annex XIII point 1(c); Article 7
Read the full regulatory guide →D
Data Carrier
The physical medium through which a Digital Product Passport is accessed. Under EU regulations, this is a QR code encoded with a GS1 Digital Link URI. The data carrier must be affixed to the product, its packaging, or accompanying documentation.
ESPR 2024/1781, Article 9
Read the full regulatory guide →Delegated Act
A legally binding EU regulation adopted by the European Commission that supplements the ESPR framework regulation. Each delegated act sets the specific DPP requirements, data fields, and compliance deadlines for a particular product category.
ESPR 2024/1781, Article 4
Read the full regulatory guide →Digital Product Passport
A structured, machine-readable data record that contains information about a product's composition, environmental footprint, durability, repairability, and supply chain. Required by EU law for an expanding set of product categories under ESPR and the Battery Regulation.
ESPR 2024/1781, Article 9
Read the full regulatory guide →E
Economic Operator
Any manufacturer, importer, distributor, authorised representative, or fulfilment service provider involved in placing a product on the EU market. Different economic operators have different obligations under DPP regulations.
ESPR 2024/1781, Article 2
Read the full regulatory guide →ESPR
Ecodesign for Sustainable Products Regulation (EU 2024/1781). The framework regulation that establishes the legal basis for Digital Product Passports across all product categories sold in the EU. Specific requirements are set through delegated acts per product category.
Regulation (EU) 2024/1781
Read the full regulatory guide →G
GS1 Digital Link
A global standard that encodes product identification data into a web URI. Used in DPP QR codes to create a standards-compliant link between the physical product and its digital passport data. The URI structure follows the GS1 Digital Link specification.
GS1 Digital Link Standard 1.3
Read the full regulatory guide →H
Hazardous Substance
A chemical substance present in a product that is classified as hazardous under EU chemicals law. For the battery passport, Annex XIII point 1(b) requires the material composition of the battery including hazardous substances present other than mercury, cadmium or lead, and Annex VI Part A point 10 requires critical raw materials present above 0,1 % weight by weight. ESPR delegated acts set their own substance requirements per product group.
REACH Regulation 1907/2006, Article 33
Read the full regulatory guide →I
Importer
Any natural or legal person established in the EU who places a product from a non-EU country on the EU market. Importers share responsibility for DPP compliance — if the non-EU manufacturer has not created a passport, the importer must.
ESPR 2024/1781, Article 4
Read the full regulatory guide →L
LMT Battery
Light Means of Transport battery: a sealed battery weighing 25 kg or less, designed to provide electric power for the traction of wheeled vehicles such as e-bikes, e-scooters and similar light electric vehicles, as defined in Article 3(11) of Regulation (EU) 2023/1542. The threshold in that definition is weight, not capacity. LMT batteries require a battery passport from February 18, 2027.
EU Battery Regulation 2023/1542, Article 3(11)
Read the full regulatory guide →M
Manufacturer
Any natural or legal person who manufactures a product, or has a product designed or manufactured, and markets that product under their name or trademark. The manufacturer is the primary responsible party for creating and maintaining a product's DPP.
ESPR 2024/1781, Article 2
Read the full regulatory guide →Market Surveillance Authority
A national authority designated by each EU Member State to enforce product compliance regulations. Market surveillance authorities can inspect DPP data, require corrections, order market withdrawal, and impose penalties for non-compliance.
Regulation (EU) 2019/1020
Read the full regulatory guide →P
Persons of Legitimate Interest
Third parties with a legitimate reason to access specific DPP data beyond the publicly available information. Under Battery Regulation Article 77(3), this includes recyclers, repairers, second-life operators, and market surveillance authorities, each with different data access tiers.
EU Battery Regulation 2023/1542, Article 77(3)
Read the full regulatory guide →R
REACH
Registration, Evaluation, Authorisation and Restriction of Chemicals, EU Regulation 1907/2006. REACH requires manufacturers and importers to identify and communicate substances of very high concern in their products. That data supports chemical disclosure in a product passport, but the battery passport itself asks for the material composition of the battery under Annex XIII point 1(b), not for a REACH SVHC declaration.
Regulation (EC) 1907/2006
Read the full regulatory guide →Recycled Content
The proportion of recycled material in a product, expressed as a percentage by weight. For batteries, Annex XIII requires declaration of recycled cobalt, lithium, nickel, and lead content, with separate pre-consumer and post-consumer shares.
EU Battery Regulation 2023/1542, Annex XIII point 1(e); Article 8(1)
Read the full regulatory guide →S
Supply Chain Due Diligence
The process of identifying, preventing, and mitigating adverse impacts in a product's value chain. For battery passports, this includes declaring the origin and certification status of critical raw materials including cobalt, lithium, nickel, manganese, and graphite.
EU Battery Regulation 2023/1542, Annex XIII point 1(d); Article 52(3); CS3D
Read the full regulatory guide →SVHC
Substance of Very High Concern, a chemical substance identified under REACH as having serious effects on human health or the environment. Under REACH, a supplier of an article containing an SVHC above 0.1 % weight by weight has notification and communication duties. Note that the EU Battery Regulation does not use this concept: the phrase "substance of very high concern" does not appear in Regulation (EU) 2023/1542, which instead requires hazardous substances present other than mercury, cadmium or lead (Annex VI Part A point 8) and critical raw materials above 0,1 % weight by weight (Annex VI Part A point 10).
REACH Regulation 1907/2006, Article 57
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